STI SP001 Inspections as part of the 2008 SPCC Amendments
What is this all about? Some background about the SPCC regulation, including specifics about tanks What tanks SP001 inspections cover Other specifics of SP001 inspections Basic inspection scheduling for SP001 Your questions
Oil spills: by the numbers 571,000 SPCC facilities 14,000 spills per year reported to the EPA Average cost of a release is $400,000 (FL DEP data)
SPCC Spill Prevention Control and Countermeasures Effective since January 10, 1974 Part of the Clean Water Act (CWA) Oil Pollution Prevention regulation Major revision 1990 as part of the Oil Pollution Act (OPA) added Facility Response Plans (FRPs) Full text found in 40 CFR 112
SPCC Applicability Oil storage in Aboveground Storage Tanks (ASTs) greater than 1320 gallons Oil storage in Underground Storage Tanks (USTs) greater than 42,000 gallons
Why SPCC? Plan to prevent discharges
Plan to respond to discharges
Floreffe, Pennsylvania 3.8 million gallon (120foot diameter) tank in Floreffe, Pennsylvania, which released approximately 750,000 gallons of oil into the Monongahela River in January 1988. Brittle-fracture failure
Exxon Valdez The largest spill in U.S. history at the time Spilled more than 11 million gallons of crude oil into Prince William Sound
Exxon Valdez In the aftermath of the Exxon Valdez incident, Congress passed the Oil Pollution Act (OPA) of 1990 OPA created the national Oil Spill Liability Trust Fund, Fund, which is available to provide up to one billion dollars per spill incident.
What goes into an SPCC Plan? Applicability
Discharge prevention
PE Certification
Record keeping
RA Amendment
Personnel training
Plan review/amendment
Security
Facility information
Diagrams
Tank information
SPCC and Industry Standards Section 112.3(d) specifically states that the PE certification of a Plan attests that “procedures for required inspections and testing have been established.” Section 112.3(d) also states that the Plan must be prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR part 112.
What standard is being used? If the facility owner or operator uses a specific standard to comply with SPCC requirements, the standard should be referenced in the Plan.
§§112.8(c)(6) and 112.12(c)(6) Test each aboveground container for integrity on a regular schedule, and whenever you make material repairs. The frequency of and type of testing must take into account container size and design (such as floating roof, skid-mounted, elevated, or partially buried). You must combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing.
§§112.8(c)(6) and 112.12(c)(6) continued You must keep comparison records and you must also inspect the container’s supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph. paragra ph.
Using a baseline The baseline must be known for an inspection and testing program to be established on a regular schedule. The inspection interval should be identified consistent with specific intervals per industry standards or should be based on the corrosion rate and expected remaining life of the container.
Establishing a baseline However, for shop-built and field-erected containers for which construction history and wall and/or bottom plate thickness baselines are not known, a regular integrity testing program cannot be established. Instead, the PE must describe in the th e SPCC Plan an interim schedule (in accordance with the introductory paragraph of §112.7) that allows the facility to gather the baseline data to establish a regular schedule of integrity testing in accordance with §§112.8(c)(6) and 112.12(c)(6).
Permanently Closed Tanks Otherwise known as: “How to take any tank out of an SPCC inspection” Remove all liquid and sludge Disconnect and blank off any piping Close and lock all valves (except vents) Post a conspicuous sign
Recordkeeping Records must be kept for a minimum of 5 years Inspections Testing Baseline conditions Training
Records can be digital but must be available onsite.
Environmental Equivalences Eleva levated ted shop-built sh op-built cont containe ainers. rs. For certain shop-built containers
with a shell capacity of 30,000 gallons or under, EPA considers that visual inspection provides equivalent environmental protection when accompanied by certain additional actions to ensure that the containers are not in contact with the soil. Shop-built cont containe ainers rs place placed d on a liner. liner. For certain shop-built
containers with a shell capacity of 30,000 gallons or under, visual inspection, plus certain additional actions to ensure the containment and detection of leaks, is also considered by EPA to provide equivalent environmental protection.
STI SP001
STI SP001 Steel Tank Institute (STI) Tank Inspection Standard Developed with US EPA
Why inspect tanks? 1.Quality assurance 2. Preventative maintenance 3. Risk reduction 4. Regulatory compliance
Owner’s responsibilities Compliance with codes, ordinances, rules and regulations Verify that people working on ASTs understand and address the hazards associated with the contents of the ASTs as well as safe entry and procedures associated with those ASTs Owner’s inspector is responsible for performing periodic AST inspections and documenting documenting the results in accordance with this standard Implement corrective actions recommended in inspections
Safety Contractor safety
Confined space entry
Fall protection
Gas testing
Breaking lines
Respiratory protection
Lockout/Tagout Tank cleaning, repair, and dismantling
Monthly inspections Visual inspections are required monthly Monthly inspections are performed by a properly trained owner’s inspector This sets the inspection frequency required by SPCC In addition, you must monitor water accumulation to prevent Microbial Influenced Corrosion (MIC), and action should be taken if MIC is found.
Formal inspections The owner is responsible making repairs or adjustments recommended by the inspector Must be performed by an STI certified inspector Can be external or internal inspections
SP001 Inspection Primary tank
Insulation covering
Secondary tank
Tank appurtenances
Tank supports
Normal vents
Tank anchors
Emergency vents
Tank foundation and external supports
Release prevention barriers
Tank gauges and alarms
Spill control systems
Spill Control Remote impounding Secondary containment berm/dike Secondary containment AST Secondary containment systems
CRDM Continuous release detection method (CRDM) Release prevention barrier (RPB). Secondary containment AST including doublewall ASTs, double-bottom ASTs, or other ASTs. Elevated AST with release prevention barrier.
What are the categories? Category 1 - ASTs with spill control, and with CRDM Category 2 - ASTs with spill control and without CRDM Category 3 - ASTs without spill control and an d without CRDM
Table 5.5, “Table of Inspection Schedules” from SP001 AST Type and Size (US Gallons)
Shop Fabricated ASTs AST s
Category 1 Category 2 Category 3
0-1,100
P
P
P, E&L(10)
1,101-5,000
P
P, E&L(10)
[P, E&L(5), I(10)] or [P, L(2), E(5)]
5,001 to 30,000
P, E(20)
[P, E(10), I(20)] or [P, E(5), L(10)]
[P, E&L(5), I(10)] or [P, L(1), E(5)]
30,001 to 50,000
P, E(20)
Field-erected AST Portable Containers
P, E&L(5), I(5) P, E&L(5), I(10)
P, E(5), I(10) P, E&L(5), I(10) P, E&L(5), I(10)
P
P
P
What are the inspection types? P – Periodic AST inspection E – Formal External Inspection by certified inspector I – Formal Internal Inspection by certified inspector L – leak test by owner or owner’s designee ( ) indicates maximum inspection interval in years. For example, E (5) indicates formal external inspection every 5 years.
Shop Fabricated AST standards for baselines API
UL
API 12F
UL142
API 650
UL 2085
SwRI SwRI 97-04 SwRI 93-01
UL 2244
Integrity Testing Types Ultrasonic thickness (UT) testing UT Scanning readings Magnetic particle testing (MT) Radiographic testing (RT) Magnetic flux testing (MFL) Penetrant testing (PT)
Leak testing methods For shop-fabricated ASTs, the standard references the Steel Tank Institute Recommended Practice R912, “Installation Instructions for Shop Fabricated Stationary Aboveground Storage Tanks for Flammable, Combustible Liquids.”
Types of LTMs Gas pressure decay Gas pressure soap bubble testing Gas tracers Soil tracers Mass measurement Level measurement Hydrostatic testing
AST Types Portable Equal or greater than 55 gallons Not intended for fixed installation Shop fabricated Equal to or less than 50,000 gallons Field erected With a nameplate: 50 feet high, 30 foot diameter (265,000 gallons) Without a nameplate: 50,000 gallons; 50’ high, 30’ diameter
Other specifications for SP001 Applies to ASTs storing stable, flammable, and combustible liquids Atmospheric pressure Tank steel must be less than 1/2” thickness Specific gravity less than approximately 1.0 Operating temperatures between ambient temperature and 200 degrees Fahrenheit (93.3/C)
Highlights SPCC regulation Applies to facilities with greater than 1320 gallons of above-ground oil storage Requires tank inspections under an industry standard SP001 inspections Owner has many responsibilities Applies to atmospheric-pressure oil storage tanks with a steel thickness less less than 1/2” Applies to ASTs from 55 gallons to 265,000 gallons Incorporates other industry standards for baseline information Formal inspections by certified inspectors include non-destructive integrity testing Periodic inspections by the owners inspector have a heavy emphasis on preventing MIC SP001 inspection scheduling for SP001 Based on factors including CRDM, spill control, tank size, and tank type
QUESTIONS?
